On 17 December 2013, the protocol amending the Agreement between Canada and Barbados for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital entered into force.

Character conversion transactions and synthetic dispositionsNo. 48, 3 October 2013

On 13 September 2013, the Department of Finance released draft legislative proposals that include a measure aimed at ensuring that derivative transactions cannot be used to convert ordinary income into capital gains through so-called “character conversion transactions,” and a measure to ensure that the tax consequences of disposing of property cannot be avoided by entering into a synthetic disposition arrangement. Interested parties are invited to provide comments by 15 October 2013.

Highlights from the CRA’s 2012-13 APA Program ReportNo. 47, 26 September 2013

On 16 August 2013, the federal government proposed draft legislation to introduce a number of revisions to the foreign affiliate dumping rules that were first announced in the 2012 federal budget and enacted on 14 December 2012 pursuant to Bill C-45. These revisions reflect certain lingering concerns that were raised during consultations on the various versions of the proposals before and even after enactment. Interested parties are invited to provide comments by 15 October 2013.

Transfer pricing is the leading tax controversy issue facing multinationals. But companies have long viewed it as a tax-only compliance issue, rather than a strategic component that can impact shareholder value. A new EY publication looks at ways to optimize intercompany transfer pricing and why this is important to chief financial officers and heads of supply chain.

On 8 May 2013, the Regulations Amending Various GST/HST Regulations, No. 4 were published in the Canada Gazette. Included among the amendments was the final version of the Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations made under the Excise Tax Act.

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